MFA Comment Letters

Topic: performance fees

Comment Letter on Joint Release Regarding Reporting by Investment Advisors to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF04.08.11


MFA filed a comment letter with the SEC and CFTC in response to their joint proposal to require private fund […]

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Topics: absolute return strategies aggregate borrowings, aggregate gross asset value, alternative methodology, asset-backed securities, assets under management, audited financial statements, balance sheet value, beneficial owners, bespoke contracts, Bloomberg, borrowing arrangements, CCPs, CDS, CDX, central clearing counterparties, CFTC, clause (iii), collateral, collateral practices, commodity pool operators, commodity trading advisors, confidentiality of information, confidentiality protections, corporate bonds, Council and Office of Financial Research, counterparty exposures, CR01, creditor, currency rates, CUSIP number, DCMs, de minimis, debt securities, default rates, delta adjusted, direct clearing members, direct investments, distressed debt, Dodd-Frank Act, duration, DV01, equity derivatives, equity exposure, equity prices, FCMs, Federal Reserve System, Financial Accounting Standards Board, Financial Stability Oversight Council, five-year option, fixed advisory fees, foreign currency contracts, foreign exchange derivatives, Form 10-K, Form 10-Q, Form 13F, Form ADV, Form CPO, Form CTA-PR, Form PF, Form PF question 36, form PF questions 28 and 35, Form PQR, FSA, funds of funds, futures commission merchants, futures contracts, GAAP, generally accepted accounting principles, global regulators, GMV, gross asset value, hedge fund assets under management, hedge fund defaults, illiquid assets, inadvertent disclosure, inception class, individual certification, interconnectedness, interest rates, interpretive guidance, Investment Adviser Registration Depository, investment advisers, investment expenses, large private fund manager, lending institutions, Level 2 inputs, Level 3 inputs, leverage, liquidity management, liquidity risk, LMV, loan commitments, long positions, managed futures, margin requirements, market noise, market participants, market value, master agreement, master-feeder, maturity brackets, maturity mismatch, NAV, net asset value, net assets under management, net borrowings, non-bank financial companies, non-rated issues, notional amount, notional value of derivatives, offsetting exposure, OFR, operational capabilities, operational efficiency, other quantitative strategies, overcounting, parallel funds, parallel managed accounts, performance fees, portfolio management, prime brokers, private equity, private fund managers, private funds, privately issued convertible bonds, proposed reporting thresholds, proprietary information, proprietary methodology, public companies, qualifying fund, record owners, recordkeeping requirements, regulatory assets under management, regulatory scrutiny, rehypothecated initial margin, reporting period, repos, risk capital allocation, risk methodology, Schedule 13G, SEC, section 404, semi-annual reporting, sensitivity analyses, short borrowing, short positions, short term high quality corporate debt, short-term interest rate, short-term market fluctuations, side pocket arrangement, SMV, statistical arbitrage-equity, strategy exposure, swap contracts, synthetic borrowing, systemic risk, systemically significant, targeted requests, ten-year option, the Fed, threshold, threshold for enhanced performance, tiered reporting system, trading and investment strategies, tri-party collateral accounts, turnover rate, UK Financial Services Authority, unaffiliated third party sources, uncommitted lines of credit, undercounting, valuation methodology, Value at Risk, VaR, variation margin,

Comment Letter Responding to the Financial Stability Oversight Council’s Advance Notice and Request for Comment on the Criteria for Designating a Nonbank Financial Company as Systemically Important.11.05.10


MFA submitted a comment letter to the Financial Stability Oversight Council in response to the Councils advance notice and request […]

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Topics: "too big to fail alignment of interests, asset mix, assets under management, bank holding companies, banks, Board of Governors, BofA Merrill Lynch, Borrowing, broker-dealer, capital markets, CFTC, Cleared Transaction, collateral, Collateral Posting, Colombia University, Common Adviser, Congress, counterparties, counterparty risk management, Counterparty Risk Management Policy Group, credit exposure, Debt Guarantees, diversified portfolio, due diligence, Equity Capital Stability, FDIC, FDIC deposit insurance, Fed Chairman Bernanke, Federal Financial Institutions Examination Council, Federal Reserve System, Federal Reserve's Discount Window, Financial Assets, financial institutions, Financial Market Participants, Financial Stability Oversight Council, financial system, FSOC, gates, global mutual fund industry, Government-Funded Capital, Government-Issed Charter, hedge fund industry, hedge funds, high water marks, Highly Illiquid Assets, Inadequate Counterparty Risk, insurance companies, Investment Company Institute, investment portfolio, Legally Distinct Funds, leverage, leverage ratio, Liquidity Restrictions, Long Term Capital Managment, LTCM, major swap participants, margin requirements, market participants, Nonbank Financial Company, off-balance sheet exposures, OTC, OTC Derivatives Trades, over-the-counter derivatives, overnight borrowing, performance fees, Periods of Redemption, Position Size, prime brokerage, Redemptions, regulatory regime, retail investors, risk monitoring, risk-adjusted returns, SEC, Securities Exchange Commission, Short-Term Funding, Side Pocket Vehicles, sophisticated investors, Standardized Transactions, Structure of the Industry, swap dealers, systemic risk, Systemic Risk Monitoring, Systemically Important Financial Companies, Systemically Important Institutions, Systemically Relevant Firms, TARP, Troubled Asset Relief Program, U.S. Banking Industry, U.S. Financial Stability, ultra-high net worth individuals, Uncleared Transaction,

MFA Comments to IOSCO’s Call for Views on Issues That Could Be Addressed by IOSCO on Funds of Hedge Funds08.03.07


MFA submits comments in response to IOSCO’s “Call for Views on Issues that Could Be Addressed by IOSCO on Funds […]

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Topics: a 5% annual return absolute return strategies, accredited investors, accrual method of accounting, acquired fund fees, administrators, advertisement, advertising rules, adviser, adviser operations, advisory contract, advisory contracts, affiliated broker, Affiliated Person, agency transactions, an oath or affirmation, annual financial statements, Annual Report, annual self-assessment, asset coverage, assets, audit, audit committee financial expert, audit-related, bank, bank custodians, board members, borrowed funds, borrowings, breaches of fiduciary duty, break-even chart, broker dealers, broker-dealer, business background, capital stock, cash purchase plan fees, CFTC, cherry picking, chief compliance officer, closed-end investment companies, codes of ethics, committee structure, commodities, Commodity Futures Trading Commission, commodity pool operator, Commodity Pools, common shares, Company Act Disclosure Requirements, Company Act FOHFs, Company Act Registration, company obligations, compensation, compliance, compliance examinations, compliance policies and procedures, conflicts of interest, Congress, counsel, counterparty creditworthiness, CPO, custodians, custody, Department of the Treasury, derivative instruments, derivative market practices, directed brokerage arrangements, Disclosure, disclosure documents, disclosure requirements, diversification, dividend reinvestment, dividends, executive session, Exemption, expenses, family of investment companies, Federal Reserve, Federal Securities Laws, fee table, fees, Financial Industry Regulatroy Authority, financial reporting to investors, FINRA, fiscal period, FOHF Report, for cause examinations, Form N-2, Form N-CSR, Form N-SAR, fraudulent or manipulative practices, Full Part 4 CPOs, Full Part 4 Funds, fund of funds, futures brokers, futures professionals, General Solicitation, global alternative investment industry, glossaries, hedge fund industry, hedge funds, high net worth requirements, high risk, independent public accountant, independent registered public accounting firm, initial investment, initial investment requirements, interest payments, interested persons, international advisory and government bodies, investment companies, investment company, Investor Protection, Investor Protection Issues, Investor Suitability, investor's capital contribution, IOSCO, IOSCO Report, IOSCO Technical Committe Standing Committee on Investment Management, IOSCO Technical Committee, legends, leverage, liability, liquidation, liquidity, major dealers, managed futures funds, management agreements, management fees, Manner of Offering, margin obligations, mass mailings, material fact, material pending legal proceedings, MFA's Sound Practices for Hedge Fund Managers, mutual, NASD, National Futures Association, natural person, net asset value, net assets, net worth, New York Stock Exchange, NFA, NFA Notice I-07-25, non-voting interests, offering, offering disclosure regime, offering price, offering prive, open-end investment companies, outstanding voting, ownership of shares, performance fees, periodic statements, periodic tender offers, personal securities transactions, Plain English Principles, Plain English Requirements, policymakers, Portfolio Holdings, portfolio managers, principal executive, principal financial officers, principal transactions, private offering exemption, private sector, private sector initiatives, promotional material, prospective investors, prospectus, proxy voting, Public Offering, public sector, public trading market, qualified clients, rask factors, real estate, record keeping requirements, recordkeeping requirements, registration statements, regulatory regime, retail funds, Retail investment, retail investors, retail investors' increased investment in FOHF's, retail market, risk factors, safe harbor, sales loads, SEC, securities, Securities and Exchange Commission, Securities Exchange Board of India, securities transactions, Senior officer code of ethics, senior securities, share repurchases, shareholder approval, shareholders, shares, soft dollar, state agencies, state securities regulators, statement of additional information, Subscription Agreement, sweep examinations, table of contents, tansferability and redemption rights, tax, tax consequences, tax status, technical terms, total annual expenses, total return, transaction fees, transactions, U.S. Funds of Hedge Funds, U.S. GAAP, U.S. generally acceped accounting principles, unaudited semi-annual reports, underlying fraud, underwriters, undistributed profits, United Kingdom's Financial Services Authority, United States, verbatim risk of loss disclosure statements, volatility, voting,
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